CFIUS Weighs in on Broadcom/Qualcomm Fight
On March 4, 2018, in a historic intervention, the Committee on Foreign Investment in the United States (CFIUS) signed an interim order mandating that Qualcomm Inc., a leading U.S. chip maker, postpone its annual meeting of shareholders for 30 days in order to provide CFIUS with time to conduct an initial review of the hostile bid by Broadcom Ltd., a Singapore-based semiconductor company.

Washington’s New Asia Map: Five International Risk Themes to Watch
State visits are usually long on pageantry and short on substance — boardrooms can be forgiven for paying little attention to them. However, President Trump’s recent visit to Asia comes at a different time: the U.S.-China bilateral relationship is under stress; a crisis on the Korean peninsula continues to confound the U.S. and its allies; and the U.S. is trying to reinvigorate a “free and open Indo-Pacific” amid some skepticism of its long-term economic commitment to the region.

US ponders complement to Cfius regime
Mario Mancuso, Boyd Greene and Luci Hague authored an article regarding newly proposed legislation that aims to broaden the power and scope of CFIUS, and related takeaways for boards and investors to consider.

The Administration Changes Course on Cuba
On November 8, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of State’s Bureau of Economic and Business Affairs, and the U.S. Department of Commerce’s Bureau of Industry and Security jointly announced changes to U.S. trade controls on Cuba.

Sanctions Compliance Lessons From Recent OFAC Actions
Mike Casey, Zach Brez and Mario Mancuso authored this article regarding the Office of Foreign Assets Control's resolution of a trio of enforcement actions against U.S.-based and foreign-organized companies that had run afoul of the Iranian Transactions and Sanctions Regulations.

The Trump Administration Sharpens Secondary Sanctions — China and Russia Are On Notice
As recently as July 25, 2017, in a wide-ranging interview with the Wall Street Journal, President Trump suggested a willingness to offer trade-related inducements to China in return for China's assistance in peacefully resolving the North Korea problem. In recent weeks, however, as the threat from North Korea has intensified, the Trump administration has signaled a shift in tactics in dealing with China, North Korea's principal economic partner and strategic ally, and Russia.

U.S. Senators Raise Questions About CFIUS and Real Estate Transactions
On May 16, 2017, Senators Ron Wyden (D-OR), Sherrod Brown (D-OH), and Claire McCaskill (D-MO) formally requested that the U.S. Government Accountability Office (“GAO”) undertake a study to assess how the Committee on Foreign Investment in the United States (“CFIUS”) evaluates real estate transactions in the United States.

Trump Administration Launches Rare Probe of the National Security Impact
of Steel Imports
On April 20, 2017, the Trump Administration announced the initiation of an investigation under Section 232 of the Trade Expansion Act of 19621 to assess the impact of steel imports on U.S. national security. This “Section 232” investigation reflects another step towards implementation of the Trump Administration’s assertive “America First” international trade agenda, and provides further indication of the president’s intent to use all available mechanisms to promote robust trade enforcement.

U.S. Imposes $1.19 Billion in Penalties on Chinese Company for Economic Sanctions and Export Control Violations
On March 7, 2017, Zhongxing Telecommunications Equipment Corporation,
headquartered in the People’s Republic of China (“PRC”), along with its subsidiaries and affiliates (collectively, “ZTE”) entered into settlement agreements with the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”); U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”); and U.S. Department of Justice (“DOJ”) to resolve civil and criminal violations of U.S. economic sanctions and U.S. export control regulations.

Dealmakers, Take Note: GAO to Study CFIUS at Congress' Urging
On October 3, 2016, the U.S. Government Accountability Office (“GAO”) announced that it would undertake an assessment of the Committee on Foreign Investment in the United States (“CFIUS”) review process to evaluate “how the current statutory and administrative authorities of the Committee on Foreign Investment in the United States have kept pace with the growing scope of foreign acquisitions in important economic sectors in the United States.” The GAO’s statement responds to a September 15 letter from 16 Members of Congress calling on the GAO to examine the advisability of identified enhancements to CFIUS’ authority and jurisdictional ambit.

Russia Sanctions Developments Highlight Need for Active Compliance Efforts
The U.S. Treasury Department's Office of Foreign Assets Control ("OFAC") has significantly expanded the number of entities and individuals subject to Russia sanctions and separately censured U.S. insurance and financial institution entities for failing to keep current with OFAC's sanctions list to prevent transactions with sanctioned parties. Economic sanctions continue to evolve as political situations change in the comprehensively sanctioned jurisdictions of Cuba, Crimea, Iran, North Korea, Sudan and Syria, as well as in countries targeted by more limited but often more complicated sanctions such as those relating to Russia, Burma/Myanmar and many other countries.

OFAC Issues New Iran Guidance
On June 8, 2016, the U.S. Department of Treasury Office of Foreign Assets Control (“OFAC”) issued new guidance in the form of frequently asked questions (“FAQs”) on the scope of sanctions relief available under the Joint Comprehensive Plan of Action (“JCPOA”).

[Simplified Chinese] Iran Sanctions: A New Era Announced
On January 16, 2016, the U.S. and EU announced that a number of sanctions on Iran have been lifted under the Joint Comprehensive Plan of Action (“JCPOA”), following verification by the International Atomic Energy Agency that Iran has met its initial commitments to scale back key aspects of its nuclear program (“Implementation
Day”).

CFIUS Annual Report to Congress: What Dealmakers Should Know
Recently, the Committee on Foreign Investment in the United States (“CFIUS”), an inter-agency committee authorized to review transactions that could result in the control of a U.S. business by a foreign person (“covered transactions”) in order to determine the effect of such transactions on the national security of the United
States, released its unclassified Annual Report to Congress for the 2014 calendar year (the “Annual Report”).

Iran Sanctions: A New Era Announced
On January 16, 2016, the U.S. and EU announced that a number of sanctions on Iran have been lifted under the Joint Comprehensive Plan of Action (“JCPOA”), following verification by the International Atomic Energy Agency that Iran has met its initial commitments to scale back key aspects of its nuclear program (“Implementation
Day”).